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2 results for “transfer pricing”+ Section 92D(3)clear

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THE PRINCIPAL COMMISSIONER OF INCOME TAX 4 MUMBAI vs. M/S S.G. ASIA HOLDINGS (INDIA) PVT. LTD

The Appeal is allowed to the aforesaid extent

C.A. No.-006144-006144 - 2019Supreme Court13 Aug 2019

Bench: HON'BLE THE CHIEF JUSTICE

3 shall exercise such powers and perform such function of Transfer Pricing Officers as mentioned in Section 92CA for the purpose of sections 92C and 92D

SAP LABS INDIA PRIVATE LIMITED vs. INCOME TAX OFFICER CIRCLE 6 (1) (1) BANGALORE

Appeals are allowed

C.A. No.-008463-008463 - 2022Supreme Court19 Apr 2023

Bench: HON'BLE MR. JUSTICE M.R. SHAH

3) of section 92D, the Assessing Officer may proceed to determine the arm's length price in relation to the said international transaction [or specified domestic transaction] in accordance with sub-sections (1) and (2), on the basis of such material or information or document available with him: Provided that an opportunity shall be given by the Assessing Officer